https://www.taxtmi.com/caselaws?id=456012 A composite offshore drilling contract requiring the supply of the drilling unit, equipment, materials and personnel was treated as a service arrangement, not a mere hiring of equipment. The receipts were therefore not characterised as equipment royalty under section 9(1)(vi) of the Income-tax Act, 1961 or Article 12 of the India-Singapore DTAA, and instead fell within the special business regime of section 44BB. As the assessee was a Singapore resident and had no permanent establishment in India under Article 5, its business profits were taxable only in Singapore under Article 7 and could not be taxed in India. The addition was deleted. en-us Mon, 07 Feb 2022 00:00:00 +0530 Fri, 21 Jun 2024 08:14:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456012 A composite offshore drilling contract requiring the supply of the drilling unit, equipment, materials and personnel was treated as a service arrangement, not a mere hiring of equipment. The receipts were therefore not characterised as equipment royalty under section 9(1)(vi) of the Income-tax Act, 1961 or Article 12 of the India-Singapore DTAA, and instead fell within the special business regime of section 44BB. As the assessee was a Singapore resident and had no permanent establishment in India under Article 5, its business profits were taxable only in Singapore under Article 7 and could not be taxed in India. The addition was deleted. Case-Laws Income Tax Mon, 07 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456012